MEMORANDUM
GILES, Chief Judge.
Mark McLaughlin ("McLaughlin" or "Mark McLaughlin") was convicted by a jury in 1996 of tax evasion under 26 U.S.C. § 7201. Following vacatur of his sentence on appeal but prior to new sentencing, McLaughlin filed a timely motion for new trial, asserting five grounds for relief: 1) that the government did not meet the requirements of Brady v. Maryland,
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